UNITED STATES EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
NORFOLK AREA OFFICE - MID-ATLANTIC REGION
IN THE MATTER OF:
Thomas D. Coates, Complainant
v.
Cox Communications, Inc., Respondent
EEOC Charge No.: 12K-2025-00001
DOJ ADA Complaint No.: 536785-LFD
DOL WHD Matter: [Insert if applicable]
FORMAL MULTI-AGENCY FILING AND CROSS-AGENCY RECORD PRESERVATION
SUBMISSION OF MOTION NO. 1 AND ADDENDUM (TWO DOCUMENTS ANNOUNCED)
TO: U.S. Equal Employment Opportunity Commission (via Portal and direct email)
CC:
- District Director, EEOC Norfolk Area Office
- Chief, U.S. EEOC (Washington DC)
- U.S. Department of Justice, Civil Rights Division (Disability Rights Section)
- U.S. Department of Labor, Wage and Hour Division
- Virginia Office of the State Inspector General
- Office of the Governor of Virginia
- Other relevant federal and state oversight agencies
RE: Cross-Agency Submission and Record Preservation - Motion No. 1 and Addendum (Two Documents)
Legal Basis for Multi-Agency Filing and Service:
This filing and all accompanying documents are submitted pursuant to:
- 42 U.S.C. § 2000e-5(b) (EEOC investigative authority and cross-agency coordination)
- 29 C.F.R. § 1601.15(c), § 1601.18 (submission and use of party statements as evidence)
- EEOC-DOL-DOJ Memorandum of Understanding (2018, revised 2022) - collaborative investigation and systemic referral
- Federal and state recordkeeping, anti-retaliation, and due process statutes
Announcement of Documents Submitted:
- Motion No. 1: Memorialization, Retaliation Timeline, and Paradigm-Shifting Addenda - This document formally requests memorialization of material statements and preservation of the record, with cross-agency distribution and relief requested.
- Addendum: Executive Knowledge, Fiduciary Breach, and the Intertwined Chain of Evidence - This addendum incorporates all related communications, documents executive awareness and inaction, and requests independent standing and cross-agency review.
Both documents are submitted together and announced for the record. All agencies are requested to acknowledge receipt and to preserve the record for further supplements or filings.
Purpose of Cross-Agency Filing:
- To ensure all filings are preserved, reviewed, and adjudicated in accordance with federal law and cross-agency standards.
- To prevent summary closure, dismissal, or unilateral determination before all pending motions and evidence are reviewed and ruled upon by leadership and oversight agencies.
- To comply with all statutory and regulatory requirements for multi-agency recordkeeping and oversight.
Notice: This header and all accompanying documents are intended to satisfy the recordkeeping, disclosure, and transmission requirements of all referenced agencies and courts. All parties are requested to preserve, review, and incorporate this record in accordance with applicable law.